HMDA Partial Exemption

Q: Our bank qualifies for the HMDA partial exemption. Some of the data points that we are exempt are things we don’t use, like credit scores or automatic underwriting systems. So in reporting these data points, should I report “Exempt” or “Not applicable” in those fields?

A: If the bank meets the partial exemption, the bank would report “Exempt/1111” for those fields if the bank is choosing to not report them.

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